On 05.07.2023, the Regulatory Authority for Waste, Energy and Water (RAWEW) provided certain guidelines in relation to the interpretation and implementation of the related provisions of Law 4685/2020 as in force concerning RES and CCHP stations with internal energy storage that can absorb energy from the grid.
Pursuant to the said Law, a RES and CCHP station with internal energy storage that can absorb energy from the grid is considered as “a RES and CCHP station which is connected to the Interconnected System or the Interconnected Network, including also the island of Crete, and includes electricity storage facilities installed behind the meter, which can store the electricity they absorb from the Transmission System or the Electricity Distribution Network to which they are connected”.
The said provision aims to distinguish RES and CCHP stations with internal storage based on whether they can absorb energy from the Network/System or not. Such criterion is a determining factor as it regards the terms of the stations’ participation in the electricity markets as well as their eligibility for participation in a state aid scheme. In particular, by virtue of the above-mentioned Law, it is stipulated that stations with internal energy storage that can absorb energy from the grid are granted a Special Works Certificate, participate in the electricity markets, are not allowed to conclude a PPA in the form of operating aid contract and are subject to certain restrictions of their total maximum power injection.
As a result, the RES and CCHP stations in question constitute a distinct and special category of stations, by taking into consideration that they are a priori excluded from receiving state aid and that they also participate in the domestic wholesale electricity market, on the one hand, through the submission of energy injection offers and on the other hand, through energy load declarations in case of charging from the grid. The different treatment of these stations compared to RES stations with internal energy storage that cannot absorb energy from the grid lies in the fact that in this case, the energy injected into the Network/System is not proven to come in its entirety from the primary RES/CCHP source, but may come from the energy that such stations have stored, following its absorption from the System/ Network to which they are connected. Therefore, the injected energy stored, as it regards the part that comes from the energy absorbed from the System/Network, is also comprised of non-RES energy.
As a result, the Law stipulates that RAWEW has the right to determine additional operational restrictions included within the context of the respective Special Works Certificates to be issued for these kinds of stations.
In addition, RAWEW further states that, by taking into account that these stations do not participate in a state aid scheme and that the factor which distinguishes them from other RES/CCHP stations, including also the ones with internal energy storage that cannot absorb energy from the grid, is the inclusion of energy storage facilities that can absorb energy from System/Network, it is clarified that the Special Works Certificates issued for these stations may concern projects that may combine different kind of RES technologies, provided that such stations include electricity storage facilities installed behind the meter.
To this end, it is noted that the in case the said requirement is fulfilled, such possibility may provide investors enhanced flexibility in order to develop projects in which for instance, wind and solar potential may be exploited in a supplementary way with the aim of ensuring the project’s maximum possible energy production.
The editorial team